International
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September 01, 2026
Valid Regs Require Abbott To Pay Tax On $8B Gain, IRS Says
The IRS urged the U.S. Tax Court to validate regulations that the agency said required Abbott Laboratories to pay taxes on an $8 billion gain stemming from transactions between its foreign affiliates, arguing the pharmaceutical giant is pushing for "an inappropriately rigid" statutory interpretation.
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September 01, 2026
China Ends Tax Break For Foreign Investor Dividends
Individual foreign investors who receive dividends and bonuses from Chinese companies with foreign capital investments are now liable for a 20% withholding tax on that income, the government said Tuesday, ending a tax break in place since 1994.
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September 01, 2026
UK Maps Out Pension Fund Inheritance Tax Reporting Rules
The U.K. government set out further detail on inheritance tax reporting rules to be rolled out for pension schemes as part of fiscal changes to bring unused pension pots into taxation in April 2027, according to a policy paper.
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September 01, 2026
Sweden To Let Unlisted Cos. E-File Withholding Tax Info
Unlisted Swedish companies that manage their own share registries would be able to file withholding tax information electronically to the Swedish Tax Agency under a bill proposed Tuesday by the Ministry of Finance.
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September 01, 2026
Temporary Tariffs Exceeded Trump's Power, Fed. Circ. Told
President Donald Trump illegally based his temporary tariffs on the misapplication of a law allowing the president to address balance-of-payment deficits, two businesses told the Federal Circuit, pushing the court to preserve a U.S. Court of International Trade ruling against the tariffs.
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September 01, 2026
Ireland Proposes Retail Investment Accounts With Flat Tax
Ireland wants to create accounts for Irish retail investors with a flat-rate tax on the account value above an exempted threshold, which would simplify the investment tax system compared to current rules, the government said.
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September 01, 2026
Frozen Tax Bands Drag 1M Pensioners Into Higher Rates
The U.K. has seen more than 1 million pensioners dragged into higher income tax bands as a result of tax thresholds being frozen for five years, according to HM Revenue & Customs data revealed Tuesday.
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September 01, 2026
UN Tax Pact Should Avoid Gross Basis Taxes, Businesses Say
The United Nations' tax convention should avoid gross basis withholding taxes, which could weaken trade and competitiveness while raising costs throughout supply chains, the International Chamber of Commerce said in comments for a consultation.
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September 01, 2026
Start Of EU Tax Simplification Talks Will Cover Anti-Avoidance
Early discussions among European Union countries on tax simplification will begin Thursday with a focus on the anti-tax avoidance directive, according to a steering note seen Tuesday by Law360.
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August 31, 2026
Siemens Urges Court Toward Wide View Of 2018 Restructuring
An attorney for Siemens USA asked the U.S. Tax Court on Monday to consider all elements of the restructuring that followed the company's 2017 acquisition of Mentor Graphics and led to a $3.5 billion deduction the following year.
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August 31, 2026
States Ask Fed. Circ. To Revive Their Temporary Tariff Claims
Two dozen states pushed the Federal Circuit on Monday to revive their specific claims against now-expired temporary tariffs while simultaneously pushing the panel to otherwise back the U.S. Court of International Trade's ruling that the tariffs were illegal.
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August 31, 2026
Investors Can't Escape Danish Tax Fraud Case, 2nd Circ. Says
Four investors and their pension plans owe $476 million for their role in a tax fraud scheme against the Danish government, the Second Circuit affirmed Monday, rejecting the investors' contention that they are beyond the reach of Danish revenue collectors.
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August 31, 2026
Levi Strauss Buyer Seeks Refund After Trump Tariffs Tossed
Levi Strauss & Co. has yet to provide a way for its customers to get refunds of unlawful tariff-related costs they had to pay for imported goods affected by President Donald Trump's since-invalidated global "tariff regime," alleges a proposed class action filed in Louisiana federal court Friday.
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August 31, 2026
Canada, France Treaties Don't Ax Investment Tax, Court Says
U.S. tax treaties with Canada and France don't shield taxpayers from the net investment income tax because the treaties' foreign tax credits are subject to limitations in the Internal Revenue Code, the Court of Appeals for the Federal Circuit said Monday, reversing two decisions.
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August 31, 2026
Tax Court Says Trader Didn't Aid In $7.3B IRS Probe
A U.S. Tax Court judge rejected a former stock trader's claim for a whistleblower award Monday, saying he did not play a significant role in Internal Revenue Service investigations into digital option tax shelters that recovered at least $7.3 billion.
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August 31, 2026
Trump Opening 1st Round Of Tariff-Free Ground Beef Tuesday
The first 100,000 of a total 300,000 metric tons of ground beef that can be imported into the U.S. without an added tariff can enter into the country starting Sept. 1, according to a proclamation published Monday.
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August 31, 2026
Canada Court Backs Ex-Blue Jays' Income Tax Formula
Two former Major League Baseball stars who played for the Toronto Blue Jays need to subtract their tax-free retirement contributions from only their Canadian income and not their U.S. earnings as well, a Canadian appeals court affirmed.
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August 31, 2026
Hong Kong's Tax Filing System Caused Trouble, Report Says
A significant number of Hong Kong taxpayers didn't finish filing taxes through the territory's online portal last year primarily because of unclear instructions, the Office of the Ombudsman said Monday.
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August 28, 2026
Canada Appeals Court Nixes Tax Liability Over $65M Mall Sale
A Canadian real estate company is off the hook for additional taxes stemming from a CA$89.8 million ($64.6 million) property sale, a Canadian appeals court ruled, rejecting a lower court's finding that the transaction was not negotiated at arm's length.
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August 28, 2026
G20 Trade Rises In Second Quarter Of 2026, OECD Says
International trade in goods and services rose substantially among the Group of 20 nations in the second quarter of this year, driven by goods imports in places like the U.S. and services exports in places like China, the OECD said Friday.
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August 28, 2026
EU Draft Tax Data Bill Eases US Access To Carveout
A draft of a European Union bill on tax data exchange seen Friday by Law360 emphasized that companies should not be barred from accessing a reporting carveout because they are headquartered in a Pillar Two side-by-side regime — a suggestion that could benefit U.S. companies.
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August 28, 2026
IRS Corrects Proposed Regs On Foreign Tax Rules
The Internal Revenue Service issued a notice Friday to correct several aspects of proposed regulations issued this month that relate to allocating foreign taxes following the repeal of a deferral election and the disallowance of foreign tax credits on certain distributions of previously taxed earnings.
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August 28, 2026
Siemens To Defend Restructuring, $3.5B Deduction At Trial
A U.S. subsidiary of German conglomerate Siemens is preparing to defend a $3.5 billion deduction stemming from transactions that the company said were needed to integrate a 2017 acquisition into its software business unit when its U.S. Tax Court trial begins Monday.
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August 28, 2026
Trade Sanctions Body Refers More Than 40 Cases To HMRC
The trade sanctions enforcer has revealed that it has referred almost 50 cases to law enforcement agencies and regulators for possible enforcement, including criminal prosecution, over the past year as its investigations begin to gather pace.
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August 27, 2026
Canadian Charity Loses Bid For Dividend Tax Refund From US
A Canadian charity cannot receive a tax refund from the Internal Revenue Service for U.S.-sourced dividend income from a unit trust because the U.S.-Canada tax treaty doesn't grant Canadian unit trusts that benefit, the United States Court of Federal Claims ruled.
Expert Analysis
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How A 1947 Tugboat Ruling May Shape Work Product In AI Era
Rapid advances in generative artificial intelligence test work-product principles first articulated in the U.S. Supreme Court’s nearly 80-year-old Hickman v. Taylor decision, as courts and ethics bodies confront whether disclosure of attorneys’ AI prompts and outputs would reveal their thought processes, say Larry Silver and Sasha Burton at Langsam Stevens.
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Navigating Privilege Law Patchwork In Dual-Purpose Comms
Three years after the U.S. Supreme Court declined to resolve a circuit split in In re: Grand Jury, federal courts remain split as to when attorney-client privilege applies to dual-purpose legal and business communications, and understanding the fragmented landscape is essential for managing risks, say attorneys at Covington.
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4 Ways GCs Can Manage Growing Service Of Process Volume
As automation and arbitration increase the volume of legal filings, in-house counsel must build scalable service of process systems that strengthen corporate governance and manage risk in real time, says Paul Mathews at Corporation Service Co.
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The Law Firm Merger Diaries: Forming Measurable Ties
Relationship-building should begin as early as possible in a law firm merger, as intentional pathways to bringing people together drive collaboration, positive client response, engagements and growth, says Amie Colby at Troutman.
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OFAC Sanctions Will Intensify Amid Global Tensions In 2026
The Office of Foreign Assets Control will ramp up its targeting of companies in the private equity, venture capital, real estate and legal markets in 2026, in keeping with the aggressive foreign policy approach embraced by the Trump administration in 2025, say attorneys at Holland & Knight.
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5 E-Discovery Predictions For 2026 And Beyond
2026 will likely be shaped by issues ranging from artificial intelligence regulatory turbulence to potential evidence rule changes, and e-discovery professionals will need to understand how to effectively guide the responsible and defensible adoption of emerging tools, while also ensuring effective safeguards, say attorneys at Littler.
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2026 Enforcement Trends To Expect In Maritime And Int'l Trade
The maritime and international trade community should expect U.S. federal enforcement to ramp up in 2026, particularly via Office of Foreign Asset Control shipping sanctions, accelerating interagency investigations of trade fraud, and U.S. Coast Guard narcotics and pollution inspections, say attorneys at Holland & Knight.
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Judges On AI: How Courts Can Boost Access To Justice
Arizona Court of Appeals Judge Samuel A. Thumma writes that generative artificial intelligence tools offer a profound opportunity to enhance access to justice and engender public confidence in courts’ use of technology, and judges can seize this opportunity in five key ways.
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The Case For Emulating, Not Dividing, The Ninth Circuit
Champions for improved judicial administration should reject the unfounded criticisms driving recent Senate proposals to divide the Ninth Circuit and instead seek to replicate the court's unique strengths and successes, says Ninth Circuit Judge J. Clifford Wallace.
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5 Tariff And Trade Developments To Watch In 2026
A new trade landscape emerged in 2025, the contours of which will be further defined by developments that will merit close attention this year, including a key ruling from the U.S. Supreme Court and a review of the U.S.-Mexico-Canada Agreement, says Ted Posner at Baker Botts.
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4 Developments That Defined The 2025 Ethics Landscape
The legal profession spent 2025 at the edge of its ethical comfort zone as courts, firms and regulators confronted how fast-moving technologies and new business models collide with long-standing professional duties, signaling that the profession is entering a period of sustained disruption that will continue into 2026, says Hilary Gerzhoy at HWG Law.
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How Fractional GCs Can Manage Risks Of Engagement
As more organizations eliminate their in-house legal departments in favor of outsourcing legal work, fractional general counsel roles offer practitioners an engaging and flexible way to practice at a high level, but they can also present legal, ethical and operational risks that must be proactively managed, say attorneys at Boies Schiller.
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How OECD Tax Update Tackles Mobile Workforce Complexity
The Organization for Economic Cooperation and Development’s recently updated model tax convention — a recalibration of international tax principles in response to an increasingly mobile workforce — should prompt companies to reevaluate cross-border operations, transfer pricing policies and tax controversy strategies, say attorneys at Eversheds.